BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
RECEIVEI)
due II
3 49 dM'97
POSTAlilATE COMMISSION
OFFICE OFTHE SECRETARY
Postal Rate and Fee Changes, 1997
)
Docket No. R97-1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SER.VICE
WITNESS SUSAN W. NEEDHAM
(OCAIUSPS-T39-8-18)
August 11, 1997
Pursuant t’o sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer Advocate hereby submits interrogatories
requests for production of documents.
and
Instructions included with OCA interrogatories
l-7 to the United States Postal Service dated Juiy 16, 1997, are hereby incorporated
Respectfully submitted,
Ad
l4I?kzL
GAIL WILLEl-TE
Director
Office of the Consumer Advocate
SHELLEY S. DREIFUSS
Attorney
by
Docket No. R97-1
OCNUSPS-T39-8.
2
Please refer to the Lotus l-2-3 spreadsheet
tile, “Pobox.wk3,”
and
to cell “AE79,” which shows the figure, 1,529, and contains the formula:
=(1651/l 10370)*AE82.
a.
Please provide a source for, or the derivation of, the figure 110,370 in the
formula in ‘cell AE79.
Please show all calculations and provide citations to all
figures used.
b.
Please confirm that the figure 1651 in the formula in cell AE79 is computed as
follows:
1651 = (1507/100770)
l
110370, where 1507 is the “Before Rates”
number of caller service customers in Group IA, and 100,770 is the “Before
Rates” total number of caller service customers from Appendix D, Schedule 3,
page 17, o’f PR.C Op. MC96-3.
the correct, figures.
If you do not confirm, please explain and provide
Please show all calculations and provide cit’ations to all
figures used.
OCPJUSPS-T39-9.
Please refer to the Lotus l-2-3 spreadsheet
file. “Pobox.wk3,”
and
to cell “Al79,” which shows the figure, 1,355, and contains the formula:
=(1445/96592)‘Al82.
96592.
Please provide a source for, or the derivation of, the figure
Please show all calculations
OCAIUSPS-T39-10.
and provide citations to all figures used.
Please refer to the Lotus l-2-3 spreadsheet
file, ‘“Pobox.wk3,”
and
to cell “A,087,” which shows the “Grand Total” of before-rates
revenues for post office
boxes, caller service and reserve numbers of $616535,639.
Also, please refer to
USPS-T,-24, Table 9B., and the “Grand Total” in the column “TYBR Revenues” of
Docket No. R97-1
$616519,399.
Please confirm that the difference between the figure in the file,
“Pobox.wk3,”
a.
3
and Table 9B., is due to rounding.
If you do not confirm, please provide the correct figure.
calculations
b.
Please Ishow all
and provide citations to all figures used.
If you do confirm, please indicate which of the two Grand Total before-rates
revenue figures should be relied upon.
OCAIUSPS-T39-,l l.
Please refer to the Lotus l-2-3 spreadsheet
tile, “‘Pobox.wk3,”
and
to cell “AS87,” which shows the “Grand Total” of after rates revenues for post office
boxes, caller service and reserve numbers of $688,001,329.
USPS-T-24,
Table 9B., and the “Grand Total” in the column “TYAR Revenues”
$688,00’1,947.
“Pobox.wk3,”
a.
of
Please confirm that the difference between the figure in the tile,
and Table 9B., is due to rounding.
If ‘you do not confirm, please provide the correct figure.
calculations
b.
Also, please refer to
Please show all
and provide citations to all figures used.
If you do confirm, please indicate which of the two Grand Total tafter-rates
revenue figures should be relied upon.
OCAIUSPS-T39-12.
Please refer to your testimony at page 31, lines ‘12-14. Please
confirm i.hat “W/P 5” of USPS-T-39 was filed in electronic format.
a.
If you do not confirm, please provide “W/P 5” in electronic format.
b.
If you do confirm that “W/P 5” was filed in electronic format, pleiase provide the
file names associated with “W/P 5.”
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Docket No. R97-1
C.
4
Please provide the file names associated with Workpapers
14, and Workpapers
6-17.
OCAAJSPS-T39-13.
a.
If you do not confirm, please explain.
only. If you do not confirm, please explain.
Please confirm that the total revenue for Certified Mail for FY 1996 is
$292,900,039.
d.
If you do not confirm, please explain.
Please confirm that the figure in part c. above consists of revenues from basic
Certified Mail transactions
e.
only, If you do not confirm, please explain.
Please explain the treatment of the ancillary service revenues for Certified Mail
from Return Receipt of $248,225,566,
OCAAJSPS-T39-14.
a.
for FY 1996 is
Please confirm1 that the figure in part a. above consists of basic Certified Mail
transactions
C.
file, “Certify.wk3.”
Please confirm that the total number of Certified Mail transactions
269,730,120.
b.
Please refer to the Lotus l-2-3 spreadsheet
and Restricted Delivery of $9,799,285.
Please refer to the Lotus l-2-3 spreadsheet
file, “Certify.wk3.”
Pllease confirm that fiscal year 1996 is the “base year” in Docket No. R97-I.
If
you do not confirm, please explain.
b.
Please provide a source for, or show the derivation of, the “Base Year” figure,
2’70.832, in cell “W23.”
Please show all calculations and provide citations to all
figures used.
C.
Please confirm that the “Base Year” figure in part b. above consists of basic
Certified Mail transactions
only. If you do not confirm, please explain.
Docket No. R97-‘I
d.
5
Please reconcile the figure in part b. above with the total number of basic
Certified Mail transactions
calculations
in cell “040.”
Please show all
and provide citations to all figures used.
OCANSPS-T39-15.
a.
of 269,730,120
Please refer to the Lotus l-2-3 spreadsheet
file, “Cettify.wk3.”
Please confirm1 that the TYBR volume is 304,153,OOO. If you da1not confirm,
please explain,,
b.
Please confirm1 that the TYBR figure in part a. above consists of basic Certified
Mail transactions
C.
only. If you do not confirm, please explain.
Please confirm1 that the TYAR volume is 293,118,OOO (see USPS-T-6 at page
IgO). If you do not confirm, please explain.
d.
Please confirm that the TYAR figure in part c. above consists of basic Certified
Mail transactions
e.
only. If you do not confirm, please explain.
Please refer to cell “W21,” which shows the figure, 286.578, and contains the
following formula:
=293.118-+3.071-3.469069.
the derivation of, the figures 3.071 and 3.469069.
Please provide sources for, or
Please show all calculations
and provide citations to all figures used.
f.
Please refer to cell “W21,” which shows the figure, 286.578, and contains the
fo’llowing formula:
=293.118-+3.071-3.469069.
Please explain the reason for
the “-+” in the formula.
OCNUSPS-T39-16.
Please refer to the Lotus l-2-3 spreadsheet
file, “Certify.wk3.”
Docket No. R97-1
a.
6
Please refer to cell “BF23,” which shows the figure, 283,148, and contains the
folrmula: =(((BB23/BB31))*BF31)-3430.362.
derivation of, the figure 3430.362.
Please provide a s,ource for, or the
Please show all calculations
and provide
citations to all figures used.
b.
Please confirm that the figure 283,148, shown in cell BF23, con!sists of basic
Certified Mail transactions
C.
only. If you do not confirm, please explain.
Please explain the relationship
between the figure 283,148, shown in cell BF23,
and the figure 286,578, shown in cell BF31.
OCANSPS-T39-17.
a.
Please refer to the Lotus l-2-3 spreadsheet
file, “Certify.wk3.”
Please refer to cell “BP33,” which shows the figure, 1.33400223’7, and contains
the formula:
=BP31/328994.
the figure 328994.
Please provide a source for, or the derivation of,
Please show all calculations and provide citations to all
figures used.
b.
Please explain the significance of the figure, 1.334002237,
OCANSPS-T39-18.
Please refer to the Lotus l-2-3 spreadsheet
shown in cell “BP33.”
file, “Certify.wk3.”
Please explain the significance of the figure, 109,885, shown in cell “BP35.”
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CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document
participalnts of record in this proceeding
in accordance with section 12 of the rules of
practice.
Attorney
Washington, D.C. 20268-0001
August II 1, 1997
upon all